VIBHU BAKHRU, J
1. These appeals - four in number - are filed under Section 260A of the Income Tax Act, 1961 (hereafter the 'Act') impugning two separate orders of the Income Tax Appellate Tribunal (hereafter 'ITAT') in respect of Assessment Years (hereafter 'AY') 1992-93 and 1993-94. Whilst ITA Nos. 163/2002 and 377/2004 are Assessee's appeals impugning ITAT's orders dated 19th December, 2001 for AY 1992-93 and 15th December, 2003 for AY 1992-93 respectively; ITA No. 260/2002 and ITA No. 537/2004 have been preferred by the Revenue against the aforementioned orders passed by ITA 163/2002 & Connected Matters Page 2 of 39 the ITAT.
2. Identical questions have been raised in the appeals preferred by the Revenue as well as the Assessee. These appeals were admitted by an order dated 21st September, 2004. Insofar as the appeals of the Revenue are concerned (being ITA Nos. 260/2002 and 537/2004), the following question of law was framed:-